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	GR NO. 159647 2005-04-15	CIR v. CENTRAL LUZON DRUG CORPORATION PANGANIBAN, J.
It is a cardinal rule that courts "will and should respect the contemporaneous construction placed upon a statute by the executive officers whose duty it is to enforce it x x x."[63] In the scheme of judicial tax administration, the need for certainty and predictability in the implementation of tax laws is crucial.[64] Our tax authorities fill in the details that "Congress may not have the opportunity or competence to provide."[65] The regulations these authorities issue are relied upon by taxpayers, who are certain that these will be followed by the courts.[66] Courts, however, will not uphold these authorities' interpretations when clearly absurd, erroneous or improper.
	GR No. 113079 2001-04-20	ENERGY REGULATORY BOARD v. CA YNARES-SANTIAGO, J.
As a general rule, contemporaneous construction is resorted to for certainty and predictability in the laws,[13] especially those involving specific terms having technical meanings.